- Counsel on holding company and operational company restructuring for multi-jurisdictional supply-chain distribution business of heavy industrial vehicle and machine part distributor in Latin America with sales throughout Latin America, Asia, and the U.S. Advise company on U.S. and cross-border tax and corporate matters pertaining to structure and U.S. shareholders.
- Representation of South American parented U.S. exporter. Matter involves ongoing counsel with U.S. and related party intercompany receivables, advising on foreign to U.S. long-term inventory receivables and U.S. tax consideration considerations and reporting of same, and providing counsel on U.S. multistate income, sales and florist tax considerations of multi-state flower sales.
- Lead counsel with respect to analysis of various intercompany debt arrangements and determination of whether such transactions were at risk of IRS recharacterization to equity under U.S. debt versus equity principles, conduct U.S. and cross border tax and corporate analysis concerning tax consequences of capitalization of such debt and corporate documentation required to effectuate transaction.
- Advised various middle market private equity groups with respect to U.S. outbound (foreign) acquisition and divestiture structuring, foreign entity rationalization, repatriation strategies, capitalization and debt structuring, and management of U.S. and foreign tax compliance and information reporting (including W-8 and FATCA considerations).
- Represented various globally active privately held middle-market foreign-based FIN-TECH companies on expansion into the U.S. and advised on debt and capitalization strategies.
- Represented various globally active privately held middle-market foreign-based FIN-TECH companies on expansion into the U.S. and advised on debt and capitalization strategies.
- Advised various middle market private equity groups with respect to U.S. outbound (foreign) acquisition and divestiture structuring, foreign entity rationalization, repatriation strategies, capitalization and debt structuring, and management of U.S. and foreign tax compliance and information reporting (including W-8 and FATCA considerations).
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